GHS Labeling Transition Product Exemption

There are three major exemptions to the GHS labeling under HazCom 2012 that are relevant to the cleaning industry:

Hand sanitizers: These products are considered "over the counter drugs" and as such the labeling of which are subject to FDA regulations, which has not adopted GHS.

Hard surface disinfectants and sanitizers: These products are subject to the labeling requirements of the Federal Insecticide, Fungicide and Rodenticide Act (FIFRA) and EPA registration. EPA has not adopted GHS.

Skin care products: These products are treated as "cosmetics" and therefore are also subject to labeling and other regulations established by FDA.